ACTION ALERT

STOP Aquatic Hitchhikers in the Great Lakes!

The United States Coast Guard is finally taking steps to address its flawed enforcement of the National Invasive Species Act (NISA) - an oversight that has contributed to invasive species introductions to the Great Lakes at a rate of one every eight months. Under NISA, the Coast Guard initiated the Great Lakes program in 1993, which requires any ocean-going vessel equipped with ballast tanks entering the Great Lakes to exchange the tank contents in the open ocean, employ an approved alternative to treat hitchhiking organisms, or retain ballast contents and seal its tanks.

So what's the problem? For the past 12 shipping seasons, the Coast Guard has exempted ships that are fully loaded with cargo and declaring "no ballast on board" (or NOBOB) from its regulations. But scientists have known for years that NOBOBs do carry invaders in their residual water and sediment. Between 70 and 80 percent of oceangoing ships that enter the Great Lakes through the St. Lawrence Seaway are NOBOBs.

The Coast Guard acknowledged this loophole in its 12-year-old program to protect the Great Lakes, and recently announced in the Federal Register that it needs to develop a comprehensive program to address NOBOB vessels. The Coast Guard is collecting public comments and will hold a public hearing on "no ballast on board" management strategies on May 9 in Cleveland, Ohio. Vocalizing your concern for the Great Lakes is needed, either through written comment, or through attending the May 9th meeting and presenting your comments to the Coast Guard. You don't have to be an expert on the complicated issues of invasive species and international shipping to care for the Lakes!

Here are points you can make:

1. Stress the need for immediate improvements: Have you been impacted by an aquatic invasive species that came from an ocean-going ship (like the zebra mussel, quagga mussel, round goby, Eurasian ruffe or spiny water flea)? Your personal experience with invasive species is an effective way to illustrate the importance of quick action to close the NOBOB loophole immediately! Unregulated NOBOBs have been entering since the 2005 shipping season opened on March 25th.

• Reduce or eliminate slop left-over in NOBOB ballast tanks

  It would be dangerous to perform ballast water exchange on a NOBOB the same way it is performed on a ship with ballast tanks full of water. Ballasted ships are required to fully flush their water in the open ocean at least three times, and reach a salinity content of 30 parts per thousand. Because a NOBOB ship is heavy with cargo, pumping tanks full could compromise the integrity of the ship and the safety of the crew. But NOBOBs can perform a modified exchange, called "swish and spit" which has been demonstrated to reduce the residual content of a NOBOB tank, install stripper pumps, or take other measures to better rid the so-called "empty" tanks of residual water and slop! The Coast Guard should require NOBOB vessels entering the Great Lakes to immediately perform important precautions like these!

• Employ an approved alternative to treat hitchhiking organisms:

  NISA allows for the Coast Guard to approve alternatives to ballast water exchange, but the Coast Guard has not finished setting the ballast water standard that it started back in 2003. Worse yet, it has no plans for enforcing or requiring the use of available treatments until 2014 or 2016. Alternative treatments and technologies cannot be refined and improved until they are put onboard ships. Tell the Coast Guard to commit to an aggressive timeline to set a biologically protective ballast water standard and support legislation authorizing the agency to immediately require best performing environmentally sound technologies for ballasted and NOBOB vessels alike! The Coast Guard needs to be a much bigger part of the solution!

• Retain ballast contents and seal its tanks:

  Failing to regulate NOBOB discharges puts the Great Lakes at risk of invasion every day of the shipping season. While sealing tanks would cost the shipping industry by modifying where a NOBOB vessel could safely travel to while within the Great Lakes, the costs are too high to the fishing industry, municipalities, and the health of the Lakes to allow business as usual. The Coast Guard has within its authority to require potentially dangerous vessels to retain its ballast tank contents and seal its tanks. Every unregulated NOBOB is potentially dangerous to the Great Lakes!

The public hearing is on May 9th, from 9am-4pm and 5pm-7pm at the Anthony J. Celebreeze Federal Building, 1240 East 9th Street, Cleveland, Ohio, 44419.

For more meeting information, the original Federal Register post, and instructions how to submit comments, go to: www.restorethelakes.org/cghearing.html Make sure you include the docket number in all your communications: USCG-2004-19842

Check the docket, and read comments from others, go to: http://dms.dot.gov/ click on "Simple Search" and search under "19842"

Please feel free to contact Jennifer Nalbone, Great Lakes United jen@glu.org, 716-213-0408 with any questions.

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